Wilson v. Vermont Castings, Inc.

170 F.3d 391 (3d Cir. 1999)

Facts

P was injured when her clothes caught on fire after starting a stove manufactured by D. P sued D under strict liability and negligence. The strict liability claim went to trial. The judge excluded the instruction manual for the stove at D’s request. The jury was asked to determine if the stove was defective and if the defect was the proximate cause of P’s injuries. The jury found that the stove was defective but that such defectiveness was not a substantial factor in causing injury to P. After the trial, P learned that a juror owned a D stove. That juror also read the instruction manual and reported to the jury the warnings contained in the manual. She also told the other jurors that the door to the unit had to be left ajar when in use. P moved for a new trial based on juror misconduct. The trial court denied the motion. P appealed. P claims the district court erred in not granting her motion for a new trial based on alleged juror misconduct.